Method, apparatus and computer program product for monitoring compliance in reporting unclaimed property

ABSTRACT

Methods, apparatus and computer program products are provided for monitoring compliance in reporting unclaimed property. The method is capable of identifying both potential non-reporters and potential under-reporters. In this regard, potential under-reporters may be identified as a result of a multilevel review that may take into account the recent reporting history, both in terms of frequency and the type and quantity of unclaimed property that has been reported. The potential non-reporters and potential under-reporters may then be further evaluated, such as by means of an audit or other follow up procedure, to insure compliance.

CROSS-REFERENCE TO RELATED APPLICATIONS

This application claims the benefit of U.S. patent application Ser. No.11/015,889, filed Dec. 17, 2004, which is incorporated herein byreference in its entirety.

FIELD OF THE INVENTION

The present application relates generally to methods, apparatus andcomputer program products for monitoring compliance in reportingunclaimed property and, more particularly, to methods, apparatus andcomputer program products for identifying candidate entities that areconsidered to have a reporting obligation and for further evaluating thecandidate entities to identify potential under-reporters.

BACKGROUND OF THE INVENTION

Many, if not most, companies have unclaimed property that is held by acompany for its rightful owner. While holding the unclaimed property, acompany is required to file reports annually with one or more statesand/or jurisdictions (hereinafter collectively referred to as “states”)and to eventually remit the unclaimed property to a state if the ownerdoes not recover the unclaimed property in the meantime. In the absenceof the rightful owner, a state holds the unclaimed property inperpetuity for the rightful owner or heir. Prior to recovery by theowner or heir, funds are used for the benefit of the state and itscitizens.

Unclaimed property generally consists of intangible personal assets andthe contents of safe deposit boxes. Intangible personal assets can bedivided into two broad categories: securities-related property andgeneral ledger property. Securities-related property includes stocks,bonds, dividends and interest. Examples of general ledger propertyinclude payroll, vendor checks, advance deposits, credit balances, giftcertificates, insurance proceeds and prepaid credit cards and otherbalances. A more complete listing of types of abandoned property isprovided by Appendix A of The Little Book About Abandoned Property,6^(th) Edition, ACS Unclaimed Property Clearinghouse (2003), thecontents of which are incorporated by reference herein.

Each state has a statute that governs the disposition of unclaimedproperty. The purposes of the statutes are generally to reunite ownerswith their unclaimed property, prevent subsequent claims by the owneragainst the company that originally held the unclaimed property onbehalf of the owner after the company has transferred the property tothe state, and to ensure that if an owner cannot be found, the economicwindfall attributable to the return on an investment of the unclaimedproperty inures to the citizens of the state, not to the company thatinitially held the unclaimed property. Pursuant to the various statestatues, property is generally considered unclaimed when there is lackof owner-generated activity. Evidence of the lack of owner-generatedactivity may include the failure to cash a check, the return ofcorrespondence or a check by the U.S. Postal Service as beingundeliverable or the absence of any other communication from the owner.Property is, in turn, considered abandoned when it remains unclaimed fora predefined number of years, as prescribed by a particular state'sstatute. The period during which the property remains unclaimed prior tobecoming abandoned is referred to as the dormancy period. Dormancyperiods vary by type of property and by state, but are frequently 3, 5or 7 years. After the dormancy period the company is required to reportthe property, either to the state of the last known address of the owneror, if the company's records do not indicate an address or identify theowner, to the company's state of incorporation. Although therequirements vary by state, companies that hold unclaimed property oftenalso have an obligation to attempt to notify the owner of the unclaimedproperty. Again, although the timing will vary depending upon eachstate's statutes, the company is eventually required to remit theabandoned property to the state of the last known address of the owneror, if the company's records do not indicate an address or otherwiseidentify the owner, to the company's state of incorporation. Reportingis an annual obligation, with reporting deadlines that vary from stateto state. Depending upon its statute, the state may then attempt tocontact the owner and, in any event, thereafter holds the abandonedproperty on behalf of the owner. While holding the property on behalf ofthe owner, however, the state can invest the abandoned property with theinterest on that investment inuring to the benefit of the state and itsresidents.

Companies have historically been relatively poor about reportingunclaimed property to the state. This poor reporting may be attributableto various factors, including the general lack of knowledge on the partof companies as to their reporting obligations. Failure to properlyreport unclaimed property may make it more difficult for the rightfulowner to reclaim the unclaimed property, since the owner may have adifficult time locating the holder of the property. Additionally,failure to properly report unclaimed property deprives the states andtheir citizens of the benefits that inure to the holder in the form ofinterest that is otherwise earned by a state's investment of theunclaimed property.

As a result of recent compliance efforts, the reporting of unclaimedproperty by companies has improved. However, it is believed that anumber of companies that hold unclaimed property, and therefore shouldreport unclaimed property, still fail to do so. Additionally, it isbelieved that a number of companies that hold unclaimed property andthat file reports with one or more states do not fully report theunclaimed property that is held. As such, these non-reporting andunder-reporting companies are not only subjecting themselves to thepenalties that may be imposed under the various state statutes governingthe reporting of unclaimed property, but the states and their citizensare deprived of the interest or other investment income from theunclaimed property that should have been remitted to the state. As such,it would be advantageous to provide improved techniques for monitoringcompliance with the reporting of unclaimed property and for furthereducating companies regarding their reporting obligations such that agreater percentage of unclaimed property is reported in compliance withthe various state statutes.

BRIEF SUMMARY OF THE INVENTION

Methods, apparatus and computer program products are therefore providedfor monitoring compliance in reporting unclaimed property. In oneembodiment, potential non-reporters and potential under-reporters areseparately identified such that an audit or other follow-up proceduremay be conducted to ensure compliance. With respect to identifyingpotential under-reporters, methods, apparatus and computer programproducts of one embodiment conduct a multi-level review in order to morecomprehensively identify potential under-reporters. As a result of themethods, apparatus and computer program products of the presentinvention, compliance in reporting unclaimed property may increase, bothas a result of further education of the reporting entities and thedeterrent effect of being identified as a potential non-reporter or apotential under-reporter, which may subject an entity to an audit orother follow-up procedure.

According to one aspect of the present invention, a method of monitoringcompliance in reporting unclaimed property receives informationregarding entities that have reported unclaimed property during at leastone prior reporting period. This information is generally maintained ina state's unclaimed property reporting records database. Typically,reporting data for at least one reporting period is required to performan analysis, however, the larger the number of report cycles availablefor review improves the quality of the analysis. Accuracy of theanalysis increases when about 10 reports or more are available forreview. A plurality of candidate entities that are considered to have areporting obligation are then identified based upon a predefinedcriteria. The candidate entities are then compared with those entitiesthat have reported unclaimed property to identify as a potentialnon-reporter any candidate entity that has not previously reportedunclaimed property. The candidate entities that previously reportedunclaimed property are further evaluated to determine if the previousreports of unclaimed property satisfied predetermined conditions and, ifnot, to identify any such candidate entities as a potentialunder-reporter.

In addition to identifying potential non-reporters and potentialunder-reporters, those entities that have filed negative reports ofunclaimed property during at least one prior reporting period are alsoidentified. Once the potential non-reporters and potentialunder-reporters have been identified, an audit, at the discretion of astate or jurisdiction, may be conducted of those candidate entities thathave been identified. As such, these candidate entities may be broughtinto compliance, if so required.

As noted above, candidate entities that previously reported unclaimedproperty are reviewed to identify potential under-reporters. In thisregard, the candidate entities that previously reported unclaimedproperty may be evaluated to determine if several differentpredetermined conditions have been met in order to determine if thecandidate entities are potential under-reporters. In one embodiment, forexample, a method of monitoring compliance and reporting unclaimedproperty initially identifies a plurality of candidate entities that areconsidered to have a reporting obligation based upon a predefinedcriteria. The candidate entities are then reviewed to determine if anycandidate entity is a potential under-reporter based on a multilevelreview. The multilevel review includes the application of one or moretest(s) selected from the group consisting of: (i) a review to determineif a respective candidate entity has recently reported unclaimedproperty, (ii) a review to identify any gaps in the recent reporting ofunclaimed property by the respective candidate entity, (iii) a review,if the respective candidate entity is a publicly traded entity, todetermine if unclaimed securities-related properties have been reported,(iv) a comparison of the unclaimed property of at least onepredetermined general ledger account that has been reported by therespective candidate entity to a predefined threshold, (v) a review ofthe types of unclaimed property expected to be reported by therespective candidate entity and (vi) a comparison of the reportinghistory of the respective candidate entity to either the reportinghistory of another entity or an anticipated reporting of a model entitywithin the same industry as a respective candidate entity. The candidateentities identified as potential under-reporters may then be audited.

In one embodiment, the comparison of the unclaimed property of at leastone predetermined general ledger account includes a comparison of one ormore of the unclaimed accounts receivable, unclaimed accounts payable,unclaimed common general ledger account and unclaimed payroll that havebeen reported by the candidate entity to respective predefinedthresholds. Additionally, in reviewing the types of unclaimed propertythat are expected to be reported by the respective candidate entities,the expectations of the types of unclaimed property that have beenreported are typically based upon the industry of the candidate entity.

In addition to the methods set forth above, an apparatus including aprocessing element and a computer program product, including at leastone computer-readable storage medium having computer readable programcode portions stored therein, are also provided for monitoringcompliance in reporting unclaimed property. Regardless of theimplementation of the present invention as a method, apparatus orcomputer program product, the various embodiments of the presentinvention assist in monitoring compliance in reporting unclaimedproperty. By identifying and then following up with potentialnon-reporters and potential under-reporters, more entities may bebrought into compliance. In addition, the awareness and knowledge ofentities as to their reporting obligations should be enhanced which, inturn, should lead to a greater percentage of unclaimed property alsobeing properly reported in future years. The general public may alsobenefit as a result of the greater compliance with the unclaimedproperty reporting requirements by providing states non-tax incomeinuring to the benefit of the state and its citizens. Additionally, thegeneral public may also benefit from the awareness of a larger number ofaccounts that may be claimed by the rightful owner or heir that resultfrom increased reporting compliance.

BRIEF DESCRIPTION OF THE SEVERAL VIEWS OF THE DRAWING(S)

Having thus described the invention in general terms, reference will nowbe made to the accompanying drawings, which are not necessarily drawn toscale, and wherein:

FIGS. 1 a and 1 b are flowcharts illustrating the operations performedin accordance with one embodiment of the present invention;

FIG. 2 is a representative screen display that is populated in creatinga profile of a candidate entity; and

FIG. 3 is a block diagram of an apparatus of one embodiment of thepresent invention.

DETAILED DESCRIPTION OF THE INVENTION

The present inventions now will be described more fully hereinafter withreference to the accompanying drawings, in which some, but not allembodiments of the inventions are shown. Indeed, these inventions may beembodied in many different forms and should not be construed as limitedto the embodiments set forth herein; rather, these embodiments areprovided so that this disclosure will satisfy applicable legalrequirements. Like numbers refer to like elements throughout.

According to the present invention, methods, apparatus and computerprogram products for monitoring compliance in reporting unclaimedproperty are provided. As initial steps, information regarding entities,such as companies, associations, partnerships and the like, that havereported unclaimed property during at least one prior reporting period,such as during a prior year is received and a plurality of candidateentities that are considered to have a reporting obligation areseparately identified based upon a predefined criteria. See steps 10 and12 of FIG. 1 a.

With respect to the entities that have reported unclaimed propertyduring a prior year, information is generally obtained from the variousstates and, in particular, from databases maintained by the states thatdefine the holders of unclaimed property known to that state. In orderto increase the accuracy of the analysis, this information is generallyobtained for a number of recent reporting periods, such as the mostrecent ten reporting periods. With respect to the identification ofcandidate entities considered to have a reporting obligation, thesecandidate entities are generally initially identified withoutconsideration as to whether or not the candidate entities havepreviously reported unclaimed property. Instead, a pool of potentialcandidates is identified and is then evaluated to determine if thepotential candidates meet a predefined criteria. The pool of potentialcandidates may be defined in various manners. For example, the pool ofpotential candidates may include all public and private companies withina particular state. From this pool of potential candidates, thecandidate entities are identified as those that meet a predefinedcriteria. Typically, the predefined criteria may be a predefined levelof annual revenue, such as $100,000,000, $80,000,000 or the like.However, other types of predefined criteria may be utilized, such asnumber of employees, value of assets, such as in the instance of a bankor other financial institution or the value of premiums written in aparticular state in the instance of an insurance company. The foregoingexamples are merely for purposes of illustration and it should beapparent that a wide variety of predefined criteria may be employeddepending up the type of entity and the number of candidate entitiesthat are desired to be identified.

The information from which the pool of potential candidates is initiallyconstructed and the information that is relied upon in order todetermine if the potential candidates satisfy the predefined criteriamay come from various sources, although Dun & Bradstreet, A. M. Best,Standard & Poor's and Lexis/Nexis are representative examples.Additionally or alternatively, this information may be derived fromfilings made by the various entities to the Securities ExchangeCommission or other governmental or organizational entities. Similarly,information may be drawn from disclosure documents filed by insurancecompanies as well as on-line information provided generally by theentity in question or from other third parties.

Once the plurality of candidate entities that meet the predefinedcriteria and which therefore are initially considered to potentiallyhave a reporting obligation are identified, a profile may be developedfor each candidate entity, as shown in step 14 of FIG. 1 a. While theprofile may include various types of information, one representativeprofile include the Federal Employer Identification Number (FEIN), theStandard Industry Code (SIC), the state of incorporation, the year ofincorporation, the year in which the business began, the type ofcompany, the annual revenue, assets or premiums written, the number ofemployees, the transfer agent in the case of a public company, theindependent certified public accountant (CPA), bankruptcy information, adescription of the business including, for example, information relatingto any recent move, the nature of the business activity and anylitigation or bankruptcy filing, brief reporting comments, the reportclassification (such as non-reporter, reporter only of negative amountsof unclaimed property, or any of the various types of under-reporters asdescribed below), the state status (such as the status of any audit orother follow up procedure), the company contact by name with title,address and telephone number. By way of example, a screen display of arepresentative profile is provided in FIG. 2.

Once the profile has been constructed, all known corporate relationshipsbetween the profiled entity and other entities are noted. In thisregard, any name changes may be noted as well as any other names underwhich the company does business, i.e., d/b/a. Additionally, allsubsidiaries of the profiled entity may be identified. In addition, allrelevant merger and acquisition activity should be noted. In thisregard, if the profiled company has been acquired, the name of theacquiring company should be identified. Similarly, if the profiledcompany has acquired another company, the acquired company should beidentified. Likewise, mergers should be identified with an indication ofthe companies that merged with the profiled company as well as anidentification as to whether the profiled company is the survivingcompany. By identifying all name changes, other names under which thecompany conducts business, all subsidiaries and all mergers andacquisition activity, the profiled company and its reporting history canmore accurately be considered during the analysis set forth since notonly the profiled company but also all related companies may becollectively considered.

The candidate entities and their related entities that have beenidentified above are then each compared with the entities that havepreviously reported unclaimed property, such as those identified by datadownloaded from a state database. See block 18 of FIG. 1 a. Based uponthis comparison, if neither the candidate entity nor any of its relatedentities have previously reported unclaimed property, the candidateentity may be identified as a potential non-reporter, while if eitherthe candidate entity or any of its related entities has previouslyreported unclaimed property, the candidate entity and its relatedentities will be further analyzed to identify if the candidate entityand its related entities have reported, but perhaps not fully, therebyunder-reporting the unclaimed property being held.

In order to accurately compare the candidate entities and their relatedentities with those entities that have previously reported unclaimedproperty, it is advantageous to develop a common representation for theentity names so as to ensure that the entities are properly matched evenif there are some minor variations, such as in punctuation,abbreviations or the like between the information that was receivedregarding entities that previously reported unclaimed property and theinformation regarding the candidate entities. See block 16. Although thenames of the entities may be represented in various fashions, onetechnique for representing the names of the entities is provided belowfor purposes of illustration but not of limitation. In this regard, anumber of predefined terms that do not serve to individually identify acompany may be removed. For example, terms such as company, corporation,incorporated, limited and the like, and abbreviations such as co.,corp., inc., ltd. or like may be removed. In order to simplify thesubsequent comparison process and to more compactly represent the namesof the various companies, common portions of a name may be representedby predefined character. For example, “National Bank” may be representedby “&c”. Furthermore, all punctuation and spaces may be removed tocreate an uninterrupted string of alphanumeric characters.

Once the name of the entities and their relationships have beenrepresented in a common fashion, one or more matching techniques may beemployed to compare and match candidate entities (hereinafter “candidateentities” will denote both the candidate entities and their relatedentities that have been identified above) that may have a reportingobligation with those entities that have previously reported unclaimedproperty. One series of matching techniques is described below forpurposes of illustration, but others may be employed without departingfrom the spirit and scope of the present invention. As an initial pointof comparison, the Federal Identification Numbers of the candidateentities may be compared with the Federal Identification Numbers ofthose entities that have previously reported unclaimed property in anystate. The complete name, as currently represented by the uninterruptedstring of alphanumeric characters, may be compared to the complete name,again as represented by the uninterrupted string of alphanumericcharacters, of the entities that have previously reported unclaimedproperty to any state to identify those that match. A further comparisonbased upon a truncated representation of the names of the candidateentities may be performed. While the names of the candidate entities maybe truncated in various fashions, the first nine bytes of the name ofeach candidate entity, as now represented by the uninterrupted string ofalphanumeric characters, is compared to the first nine bytes of thenames of the entities that have previously reported unclaimed propertyto any state, as also now represented by the uninterrupted string ofalphanumeric characters, with matches therebetween being identified.This additional level of matching is to try and identify entities thathave different endings which may occur occasionally due to truncation ofwords.

While each of the foregoing comparisons has been performed with theinformation relating to the reporting history of entities from allstates, i.e., entities that have previously reported unclaimed propertyto any state, an additional comparison may be made based upon thereporting history provided by a particular state. While variouscomparisons may be made, the comparison is generally simpler and lessrestrictive since the number of entities that have reported unclaimedproperty to a specific state are a smaller group than those previouslyconsidered. In this regard a comparison of a truncated portion of thename of each candidate entity, as now represented by the uninterruptedstring of alphanumeric characters, is made to a similarly truncatedrepresentation of the names of the entities that previously reportedunclaimed property to the particular state, again as represented by anuninterrupted string of alphanumeric characters. As noted more generallyabove, since the comparison is made based upon the data provided by aparticular state, the names may be further truncated in order toidentify additional matches that were not previously identified whenconsidering the reporting history provided by all states. While thenames may be truncated in various manners, the names of one embodimentare truncated such that the first seven bytes of the name of eachcandidate entity is compared with the first seven bytes of the names ofthe entities that previously reported unclaimed property to theparticular state to identify matches.

If desired, a manual process is then performed to confirm the matchesautomatically identified in the above-described manner and to remove anyfalse matches. In addition, further matches may be identified bysearching on unique words within the entity name to identify otherformats of the name entered, and to also try to identify anymisspellings of entity names.

The candidate entities that remain unmatched following the variousmatching routines will generally be considered to be potentialnon-reporters. Entities that have previously filed negative reports ofunclaimed property only are considered and treated in the same fashionas potential non-reporters.

Of the candidate entities that were matched in one of the precedingsteps with entities that had previously reported unclaimed property, afurther evaluation of these candidate entities is conducted to determineif these candidate entities have potentially underreported unclaimedproperty. In one advantageous embodiment, the candidate entities thathave been matched with an entity that previously reported unclaimedproperty are evaluated based upon a multilevel review, as shown in block20 of FIG. 1 a. In this regard, the method, apparatus and computerprogram product of one embodiment of the present invention conduct aseries of tests to evaluate whether or not a candidate entity is apotential under reporter, as described below. It is noted, however, thatnot all of the following tests need be conducted and, instead, themultilevel review may consist of any combination of the following tests.

In one embodiment, the candidate entities that were matched to an entitythat previously reported unclaimed property are initially evaluated todetermine if the candidate entities previously reported unclaimedproperty recently to a particular state. The time frame for determiningwhether a candidate entity has recently reported unclaimed property maybe defined in various manners. In one embodiment, however, a candidateentity is considered to have recently reported unclaimed property if thecandidate entity has reported unclaimed property within a predefinednumber of years, such as within the last five years. If the candidateentity is determined not to have reported unclaimed property within thepredefined number of years, the candidate entity may be categorized as apotential under-reporter. If the candidate entity has reported unclaimedproperty within the predefined number of years, the reporting history ofthe candidate entity may be evaluated to determine if the candidateentity has reported unclaimed property in each of the predefined years,such as in each of the last five years. If the candidate entity has notreported in one or more of the predefined years such that a gap inreporting exists, the candidate entity may also be categorized as apotential under-reporter.

For candidate entities that have reported unclaimed property in each ofthe predefined years, the type and/or the quantity of unclaimed propertyis then examined to determine if it is appropriate. In this regard, ifthe candidate entity is a publicly traded company, the reporting historyof the candidate entity is reviewed to determine if the candidate entityhas reported unclaimed securities-related properties, such as unclaimedshares of stock and related dividends. If so, the evaluation of thecandidate entity may continue as described below. If not, however, thecandidate entity may be considered a potential under reporter sincealthough the candidate entity has reported unclaimed property in therecent past, the candidate entity has not reported unclaimedsecurities-related properties as would be expected of a publicly tradedcompany.

Thereafter, the candidate entities may be subjected to one or moregeneral ledger-related tests. In this regard, the unclaimed propertythat has been reported by the candidate entity from each of severalspecific general ledger accounts may be evaluated in comparison torespective predefined thresholds. In this regard, the unclaimed accountsreceivables (A/R) that have been reported by the candidate entity arecompared to a prefined A/R threshold. Likewise, the unclaimed accountspayable (A/P) and the unclaimed common general ledger accounts arecompared to predefined A/P and common general ledger thresholds,respectively. In addition, the unclaimed payroll that has been reportedby the candidate entity is compared to a predefined payroll threshold.

The average annual predefined thresholds may differ from one another andmay be defined in any desired manner. In one embodiment, the predefinedA/R, A/P and common general ledger thresholds may all be defined toequal $5000, while the predefined payroll threshold is defined to be$1000. However, the thresholds need not be defined to equal a singlevalue, but may, instead, be defined to vary in a predefined manner basedupon one or more parameters. For example, the thresholds may be definedto equal a predetermined percentage of the gross revenues, assets orpremiums written by a respective candidate entity. Still further,several different values may be defined for the thresholds with theparticular value being selected based upon one or more parameters, suchas the industry sector, gross revenues, assets or premiums written by arespective candidate entity.

A candidate entity may be considered to be a potential under reporter ifthe candidate entity fails a predefined number of the general ledgertests. For example, a candidate entity may be considered to be apotential under reporter in one embodiment if the candidate entity failsany two of the general ledger tests.

The type of unclaimed property previously reported by a candidate entitymay then be further evaluated to determine if the most likely types ofunclaimed property have been reported. Since the type of unclaimedproperty that is reported generally varies based upon the industrysegment of the candidate entity, the industry segment of the candidateentity may be identified, such as by consideration of the SIC codeassociated with the candidate entity. In one embodiment, for example,the industry segment of the candidate entity is identified based uponthe first two digits of the SIC code. As will be apparent, the industrysegment can be identified with more or less granularity, if so desired.According to this test, the type(s) of unclaimed property that shouldmost frequently be reported are predefined for each respective industrysegment. For example, utilities will commonly report deposit refunds orinsurance companies will commonly report benefit disbursements. As such,each candidate entity may be evaluated based upon its industry segmentto determine if the type(s) of unclaimed property that should mostfrequently be reported by companies within the respective industrysegment have been reported. If not, the candidate entity may beconsidered an under reporter since although the candidate entityreported unclaimed property, the candidate entity did not report theexpected type(s) of unclaimed property.

If the candidate entity has reported the expected types of unclaimedproperty and has otherwise passed each of the foregoing tests, thecandidate entity may not be flagged as a potential under reporter andmay therefore not be subjected to further review as described below. Inone embodiment, however, a candidate entity that has reported theexpected types of unclaimed property and has otherwise passed each ofthe foregoing tests may still be subjected to an additional overalltest. In this regard, the reporting profile of a company within the sameindustry segment as the candidate entity that has properly reported anaverage and/or an anticipated amount of unclaimed property of theexpected type(s) may be constructed. This reporting profile may be basedupon an actual company within the same industry segment that is known tohave properly reported an average and/or anticipated amount of unclaimedproperty of the expected type(s). Alternatively, the reporting profileof a hypothetical company in the same industry segment may beconstructed that is considered to have reported an average and/oranticipated amount of unclaimed property of the expected type(s).

The candidate entity is compared to the predefined reporting profile. Ifthe candidate entity is found to have reported the expected type(s) ofunclaimed property in at least the average and/or anticipated amounts,the candidate entity will be considered to have passed this additionaltest. Instead of having to have reported unclaimed property of theexpected type(s) in amounts that meet or exceed the average and/oranticipated amounts, other tests may be employed such as by permittingthe candidate entity to pass the test even if the candidate entity hasreported less than the average and/or anticipated amounts so long as thecandidate entity has reported amounts that are within a predeterminedpercentage, either on an individual basis or in the aggregate, of theaverage and/or anticipated amounts. If the candidate entity is found tohave not reported the average and/or anticipated amounts of the expectedtype(s) of unclaimed property as defined by the predefined reportingprofile or to have otherwise failed this test, the candidate entity mayagain be categorized as a potential under reporter.

While a variety of tests have been described above that all must besuccessfully passed by a candidate entity that has previously reportedunclaimed property to avoid classification as a potential underreporter, it should be apparent to those skilled in the art that theforegoing tests are provided by way of illustration and not oflimitation. In this regard, the multilevel review of this embodiment ofthe present invention may employ any of the foregoing tests, in order toidentify potential under reporters. By employing a wide variety of testsas described above that not only merely confirm reporting with the statein question, but also confirm that anticipated amounts have beenreported for different expected types of unclaimed property, a morecomprehensive review of the reporting history of a candidate entity maybe conducted. As such, additional potential under reporters may beidentified, while avoiding any further review of entities that appear tobe properly reporting unclaimed property.

Information relating to the potential non-reporters and the potentialunder reporters may be provided to a state via various reports as shownin block 22 of FIG. 1 b. In one embodiment, for example, the state isprovided access to a web interface via which the reports and otherinformation can be delivered. Included in this information regarding thepotential non-reporters and the potential under reporters may be aproposal identifying the potential non-reporters and the potential underreporters that should initially be subject to a further review, as shownin block 24.

In this regard, for those candidate entities that have been identifiedas a potential non-reporter or a potential under reporter, furtherreview may be conducted as dictated by the state, such as in a tieredapproach as described below. First, the potential non-reporter orpotential under reporter may be contacted and additional informationrelevant to the reporting of unclaimed property may be collected. Seeblock 26. Based on this additional information, a more detailed andindividualized analysis of the reporting history of the entity may beconducted. If, as a result of this more detailed analysis, it isdetermined that the entity has properly reported its unclaimed property,the entity may reclassified so as to no longer be considered either apotential non-reporter or a potential under reporter.

If the additional information is not provided or is incomplete or if themore detailed analysis does not indicate that the entity has properlyreported its unclaimed property, it may be such that during the processof collecting and providing the additional information, the entity haslearned more about the unclaimed property reporting requirements of thestate and, as a result, may reevaluate its prior reporting history andcure any deficiencies that are noted, thereby also allowing the entityto be reclassified so as to no longer be considered either a potentialnon-reporter or a potential under reporter. Alternatively, if theinitial request for additional information does not evidence that theentity has properly reported its unclaimed property and if the entitydoes not voluntarily bring its unclaimed property reporting intocompliance, an audit or other review may be conducted by the state or athird party that is acting on behalf of the state. See block 28. Assuch, further details regarding the unclaimed property held by theentity and its reporting history may be obtained such that a moredetailed analysis can be conducted to determine if the entity hasproperly reported the unclaimed property that it holds. If this moredetailed review reveals that the entity has properly reported theunclaimed property, the entity is recategorized so as no longer to beconsidered a potential non-reporter or a potential under reporter. If,however, the entity fails to cooperate or if the more detailed reviewindicates that the entity has not properly reported the unclaimedproperty that it holds, the state may pursue the enforcement proceduresthat are generally defined by state statute to obtain proper reportingand delivery of the unclaimed property that should have been remitted tothe state. See block 30. Alternatively, the entity may have learned moreabout its reporting obligations during the audit and reevaluated itsreporting history and may voluntarily cure any deficiencies that arenoted in order to permit the entity to be reclassified so as no longerbe considered either a potential non-reporter or a potential underreporter.

Throughout the process of collecting additional information andconducting a further review and/or audit, additional reports and otherinformation may be provided to the state, such as via the web interface,as shown in block 32. Following completion of the process, the ongoingcompliance of the entities may continue to be monitored and anyappropriate follow up activities undertaken to insure continuedcompliance. See block 34. Upon completing this more detailed reviewprocess for one or a group of potential non-reporters or potential underreporters, this more detailed review may be proposed to the state forany additional potential non-reporters or potential under reporters thathave been preliminarily identified, but have not yet been reviewed indetail.

In addition to the foregoing inventive methods, an apparatus is providedaccording to another aspect of the present invention that is capable ofoperating in accordance with the various embodiments that have beendescribed above. In this regard, the apparatus may be embodied in one ormore computer systems, such as one or more of a laptop computer, desktopcomputer, server computer or the like. As shown in FIG. 3, the apparatusgenerally includes a processing element 40, such as a processor or othercomputing device, connected to at least one interface or other means fordisplaying, transmitting and/or receiving data, content or the like. Inthis regard, the interface(s) can include at least one communicationinterface or other means for transmitting and/or receiving data, contentor the like, such as between the processing element and the statedatabases 42 and other sources 44 of information, as well as at leastone user interface that can include, for example, a display 46 and/or auser input interface 48. The user input interface, in turn, can compriseany of a number of devices allowing the entity to receive data from auser, such as an electronic scanner, keyboard, mouse and/or any of anumber of other devices, components or the like capable of receivingdata, content or the like.

In addition to the interfaces, the processing element 40 can beconnected to a memory 50. The memory can comprise volatile and/ornon-volatile memory, and typically stores content, data or the like. Inthis regard, the memory typically stores software applications,instructions or the like for directing the processing element to performsteps in accordance with embodiments of the present invention.

As described above, the apparatus and, in particular, the processingelement 40 generally operates under control of a computer programproduct. The computer program product for performing the methods ofembodiments of the present invention includes a computer-readablestorage medium, such as the non-volatile storage medium, andcomputer-readable program code portions, such as a series of computerinstructions, embodied in the computer-readable storage medium.

In this regard, FIGS. 1 a and 1 b are flowcharts of methods, systems andprogram products according to embodiments of the present invention. Itwill be understood that each block or step of the flowchart, andcombinations of blocks in the flowchart, can be implemented by computerprogram instructions. These computer program instructions may be loadedonto a computer or other programmable apparatus to produce a machine,such that the instructions which execute on the computer or otherprogrammable apparatus create means for implementing the functionsspecified in the flowchart block(s) or step(s). These computer programinstructions may also be stored in a computer-readable memory that candirect a computer or other programmable apparatus to function in aparticular manner, such that the instructions stored in thecomputer-readable memory produce an article of manufacture includinginstruction means which implement the function specified in theflowchart block(s) or step(s). The computer program instructions mayalso be loaded onto a computer or other programmable apparatus to causea series of operational steps to be performed on the computer or otherprogrammable apparatus to produce a computer implemented process suchthat the instructions which execute on the computer or otherprogrammable apparatus provide steps for implementing the functionsspecified in the flowchart block(s) or step(s).

Accordingly, blocks or steps of the flowchart support combinations ofmeans for performing the specified functions, combinations of steps forperforming the specified functions and program instruction means forperforming the specified functions. It will also be understood that eachblock or step of the flowchart, and combinations of block(s) or step(s)in the flowchart, can be implemented by special purpose hardware-basedcomputer systems which perform the specified functions or steps, orcombinations of special purpose hardware and computer instructions.

The foregoing methods, apparatus and computer program products of thevarious aspects of the present invention therefore provide a mechanismfor identifying entities that have not reported or are likely to haveunder reported unclaimed property such that more intensive evaluationsof these entities may be conducted to determine if the entities have notcomplied with the reporting obligations mandated by the state. As such,the methods, apparatus and computer program products of the presentinvention may lead to greater compliance with the unclaimed propertyreporting requirements of the states. Beneficially, the interaction withthe entities that have been identified as potential non-reporters orpotential under reporters may serve to further educate the entities asto their reporting obligations so that not only are the entities broughtinto current compliance with the unclaimed property reportingrequirements, but the entities are more likely to properly reportunclaimed property in the future without requiring further audits orother individualized measures. Because of the greater compliance withthe unclaimed property reporting requirements attributable to thepresent invention, a greater percentage of the unclaimed property shouldbe remitted to the states, thereby resulting in increased interest orother investment income which inures to the benefit of the citizens ofthe states

Many modifications and other embodiments of the inventions set forthherein will come to mind to one skilled in the art to which theseinventions pertain having the benefit of the teachings presented in theforegoing descriptions and the associated drawings. Therefore, it is tobe understood that the inventions are not to be limited to the specificembodiments disclosed and that modifications and other embodiments areintended to be included within the scope of the appended claims.Although specific terms are employed herein, they are used in a genericand descriptive sense only and not for purposes of limitation.

That which is claimed:
 1. A method, comprising: receiving, by aprocessor, information from a database, the information regarding afirst group of entities that have reported unclaimed property during atleast one prior reporting period; identifying, by the processor,candidate entities that are considered to have a reporting obligation,the identifying of the candidate entities is based upon a predefinedcriteria; comparing, by the processor, a common representation of eachof the candidate entities with the information regarding the first groupof entities; identifying, by the processor and based on the comparing,any of the candidate entities that has not previously reported unclaimedproperty as a potential non-reporter entity; identifying, by theprocessor, any of the candidate entities that has previously reportedunclaimed property as previously reported candidate entities;evaluating, by the processor, previous reports of unclaimed property,the previous reports are associated with the previously reportedcandidate entities, to determine whether the previous reports satisfypredetermined conditions, the predetermined conditions are differentthan the predefined criteria; when at least one of the previous reportsdo not satisfy the predetermined conditions, identifying by theprocessor at least one potential under-reporter entity from thepreviously reported candidate entities; associating, by the processor,negative reports of unclaimed property during the at least one priorreporting period with at least one respective candidate entity of thecandidate entities; and outputting, by the processor, informationregarding at least one of the candidate entities.
 2. The methodaccording to claim 1 further comprising conducting, by the processor, afollow-up procedure specific to a candidate entity identified as atleast one of a potential non-reporter entity and a potentialunder-reporter entity.
 3. The method according to claim 1, whereinevaluating the previously reported candidate entities comprisesdetermining if any of the previously reported candidate entities hasreported unclaimed property within a predefined number of priorreporting periods.
 4. The method according to claim 1, whereinevaluating the previously reported candidate entities comprisesidentifying any gaps in the recent reporting of unclaimed property byany of the previously reported candidate entities.
 5. The methodaccording to claim 1, wherein when a respective candidate entity of thepreviously reported candidate entities is a publicly traded entity, saidevaluating the respective candidate entity comprises determining ifunclaimed securities related properties have been reported for therespective candidate entity.
 6. The method according to claim 1, whereinevaluating the previously reported candidate entities comprisescomparing unclaimed property of at least one predetermined ledgeraccount that has been reported by a respective candidate entity to apredefined threshold.
 7. The method according to claim 1, whereinevaluating the previously reported candidate entities comprisescomparing unclaimed property reported by a respective candidate entityof the previously reported candidate entities with types of unclaimedproperty expected to be reported.
 8. The method according to claim 1,wherein evaluating the previously reported candidate entities comprisescomparing, by the processor, unclaimed property reported by a respectivecandidate entity of the previously reported candidate entities with areporting history of another entity or with an anticipated reporting ofa model entity within the same industry as the respective candidateentity.
 9. The method according to claim 1, wherein evaluating thepreviously reported candidate entities comprises reviewing thepreviously reported candidate entities to determine if any of thepreviously reported candidate entities is a potential under-reporterbased on a multilevel review comprising tests selected from the groupconsisting of: (i) a review to determine if a respective candidateentity of the previously reported candidate entities has recentlyreported unclaimed property, (ii) a review to identify any gaps in therecent reporting of unclaimed property by the respective candidateentity, (iii) when the respective candidate entity is a publicly tradedentity, a review to determine if unclaimed securities-related propertieshave been reported, (iv) a comparison of unclaimed property of at leastone predetermined general ledger account that has been reported by therespective candidate entity to a predefined threshold, (v) a review oftypes of unclaimed property expected to be reported by the respectivecandidate entity, and (vi) a comparison of a reporting history of therespective candidate entity to one of the reporting history of anotherentity or an anticipated reporting of a model entity within the sameindustry as the respective candidate entity.
 10. The method according toclaim 9 further comprising conducting, by the processor, an audit of apotential under-reporter of the at least one potential under-reporterentity.
 11. The method according to claim 9, wherein the comparison ofthe unclaimed property of the at least one predetermined general ledgeraccount comprises a comparison of at least one of unclaimed accountsreceivables, unclaimed accounts payable and unclaimed payroll that hasbeen reported by the respective candidate entity to respectivepredefined thresholds.
 12. The method according to claim 9, wherein thereview of the types of unclaimed property comprises a review of thetypes of unclaimed property expected to be reported by the respectivecandidate entity based upon the respective candidate entity's industry.13. A system, comprising: a database configured to store informationregarding a first group of entities that have reported unclaimedproperty during at least one prior reporting period; a computing deviceconfigured to: receive the information regarding the first group ofentities from the database; identify candidate entities that areconsidered to have a reporting obligation, the candidate entities areidentified based upon a predefined criteria; compare a commonrepresentation of each of the candidate entities with the informationregarding the first group of entities to identify any of the candidateentities that has not previously reported unclaimed property as apotential non-reporter entity; identify any of the candidate entitiesthat previously reported unclaimed property as previously reportedcandidate entities; evaluate previous reports of unclaimed property, theprevious reports are associated with the previously reported candidateentities, to determine whether the previous reports satisfypredetermined conditions, the predetermined conditions are differentthan the predefined criteria; when the previous reports of unclaimedproperty do not satisfy the predetermined conditions, identify at leastone potential under-reporter entity from the previously reportedcandidate entities; associate negative reports of unclaimed propertyduring the at least one prior reporting period with a respectivecandidate entity of the candidate entities; and output informationregarding at least one of the candidate entities.
 14. The systemaccording to claim 13, wherein said computing device is configured toevaluate the previously reported candidate entities to determine if anyof the previously reported candidate entities has reported unclaimedproperty within a predefined number of prior reporting periods.
 15. Thesystem according to claim 13, wherein said computing device isconfigured to evaluate the previously reported candidate entities toidentify any gaps in the recent reporting of unclaimed property by anyof the previously reported candidate entities.
 16. The system accordingto claim 13 wherein, when a respective candidate entity of thepreviously reported candidate entities is a publicly traded entity, saidcomputing device is configured to determine if unclaimed securitiesrelated properties have been reported for the respective candidateentity.
 17. The system according to claim 13, wherein said computingdevice is configured to evaluate the previously reported candidateentities by comparing unclaimed property of at least one predeterminedledger account that has been reported by a respective candidate entityto a predefined threshold.
 18. The system according to claim 13, whereinsaid computing device is configured to evaluate the previously reportedcandidate entities by comparing unclaimed property reported by arespective candidate entity of the previously reported candidateentities with types of unclaimed property expected to be reported. 19.The system according to claim 13, wherein said computing device isconfigured to evaluate the previously reported candidate entities bycomparing unclaimed property reported by a respective candidate entityof the previously reported candidate entities with a reporting historyof another entity or with an anticipated reporting of a model entitywithin the same industry as the respective candidate entity.
 20. Thesystem according to claim 13, wherein said computing device is furtherconfigured to review the candidate entities to determine if anypreviously reported candidate entities is a potential under-reporterbased on a multilevel review comprising tests selected from the groupconsisting of: (i) a review to determine if a respective candidateentity of the previously reported candidate entities has recentlyreported unclaimed property, (ii) a review to identify any gaps in therecent reporting of unclaimed property by the respective candidateentity, (iii) when the respective candidate entity is a publicly tradedentity, a review to determine if unclaimed securities-related propertieshave been reported, (iv) a comparison of unclaimed property of at leastone predetermined general ledger account that has been reported by therespective candidate entity to a predefined threshold, (v) a review oftypes of unclaimed property expected to be reported by the respectivecandidate entity, and (vi) a comparison of a reporting history of therespective candidate entity to one of the reporting history of anotherentity or an anticipated reporting of a model entity within the sameindustry as the respective candidate entity.
 21. The system according toclaim 20, wherein said computing device is configured to make thecomparison of unclaimed property of the at least one predeterminedgeneral ledger account by comparing at least one of unclaimed accountsreceivables, unclaimed accounts payable and unclaimed payroll that hasbeen reported by the respective candidate entity to respectivepredefined thresholds.
 22. The system according to claim 20, whereinsaid computing device is configured to conduct the review of the typesof unclaimed property by reviewing the types of unclaimed propertyexpected to be reported by the respective candidate entity based uponthe respective candidate entity's industry.
 23. A computer programproduct for monitoring compliance in reporting unclaimed property, thecomputer program product stored on at least one non-transitorycomputer-readable storage medium comprising computer-readable programcode portions stored therein, the computer-readable program codeportions when executed cause a machine to: receive information, from adatabase, regarding entities that have reported unclaimed propertyduring at least one prior reporting period; identify candidate entitiesthat are considered to have a reporting obligation, the candidateentities are identified based upon a predefined criteria; compare thecandidate entities with the entities to identify any of the candidateentities that has not previously reported unclaimed property as apotential non-reporter entity; identify any of the candidate entitiesthat previously reported unclaimed property as previously reportedcandidate entities; evaluate previous reports of unclaimed property, theprevious reports are associated with the previously reported candidateentities, to determine whether the previous reports satisfypredetermined conditions, the predetermined conditions are differentthan the predefined criteria, and, when the previous reports ofunclaimed property do not satisfy the predetermined conditions, toidentify at least one potential under-reporter entity from thepreviously reported candidate entities; associate negative reports ofunclaimed property during the at least one prior reporting period with arespective candidate entity of the candidate entities; and outputinformation regarding at least one of the candidate entities.
 24. Thecomputer program product according to claim 23, wherein evaluating thepreviously reported candidate entities includes causing the machine todetermine if any of the previously reported candidate entities hasreported unclaimed property within a predefined number of priorreporting periods.
 25. The computer program product according to claim23, wherein evaluating the previously reported candidate entitiesincludes causing the machine to identify any gaps in the recentreporting of unclaimed property by any of the previously reportedcandidate entities.
 26. The computer program product according to claim23 wherein, when a respective candidate entity of the previouslyreported candidate entities is a publicly traded entity, said fifthexecutable portion is configured to determine if unclaimed securitiesrelated properties have been reported for the respective candidateentity.
 27. The computer program product according to claim 23, whereinevaluating the previously reported candidate entities includes causingthe machine to compare unclaimed property of at least one predeterminedledger account that has been reported by a respective candidate entityto a predefined threshold.
 28. The computer program product according toclaim 23, wherein evaluating the previously reported candidate entitiesincludes causing the machine to compare the unclaimed property reportedby a respective candidate entity of the previously reported candidateentities with types of unclaimed property expected to be reported. 29.The computer program product according to claim 23, wherein evaluatingthe previously reported candidate entities includes causing the machineto compare unclaimed property reported by a respective candidate entityof the previously reported candidate entities with a reporting historyof another entity or with an anticipated reporting of a model entitywithin the same industry as the respective candidate entity.
 30. Thecomputer program product according to claim 23, wherein evaluating thepreviously reported candidate entities includes causing the machine toreview the previously reported candidate entities to determine if any ofthe previously reported candidate entities is a potential under-reporterbased on a multilevel review comprising tests selected from the groupconsisting of: (i) a review to determine if a respective candidateentity of the previously reported candidate entities has recentlyreported unclaimed property, (ii) a review to identify any gaps in therecent reporting of unclaimed property by the respective candidateentity, (iii) when the respective candidate entity is a publicly tradedentity, a review to determine if unclaimed securities-related propertieshave been reported, (iv) a comparison of unclaimed property of at leastone predetermined general ledger account that has been reported by therespective candidate entity to a predefined threshold, (v) a review oftypes of unclaimed property expected to be reported by the respectivecandidate entity, and (vi) a comparison of a reporting history of therespective candidate entity to one of the reporting history of anotherentity or an anticipated reporting of a model entity within the sameindustry as the respective candidate entity.
 31. The computer programproduct according to claim 23, wherein making the comparison of theunclaimed property of the at least one predetermined general ledgeraccount includes causing the machine to compare at least one ofunclaimed accounts receivables, unclaimed accounts payable and unclaimedpayroll that has been reported by the respective candidate entity torespective predefined thresholds.
 32. The computer program productaccording to claim 23, wherein conducting the review of the types ofunclaimed property includes causing the machine to review the types ofunclaimed property expected to be reported by the candidate entity basedupon the respective candidate entity's industry.